Alpha has been very engaged with critical industry stake holders1 regarding the Conflict Minerals issue and regulation over the last two years. On August 22, 2012, the U.S. Securities and Exchange Committee ("SEC") published the final rules of implementation of Section 1502 of the Dodd Frank Act regarding Conflict Minerals. This section of the Act was enacted by Congress in order to help eradicate the sales of "Conflict Minerals" from the Democratic Republic of Congo (“DRC”) and adjoining countries (the “Conflict Countries”) whose sale of which today finances armed militant groups participating in regional conflicts.
This US SEC Act requires any US Publicly held company to annually disclose its use of conflict minerals that originated in the Conflict Countries. Conflict minerals are those minerals whose derivatives are Tin, Tantalum, Tungsten or Gold.
The final rules, if conflict minerals are "necessary to the functionality or production of a product manufactured, or contracted to be manufactured", by a US Public company, said company will be required to file a report annually disclosing whether its conflict minerals originated in a Conflict Country, based on its reasonable country of origin inquiry. If a company or its suppliers' reasonable country mine of origin inquiry reveals that the material was sourced from a "Conflict Country" an additional level of due diligence is required based on an internationally recognized 3rd party and audit process.
For more information about Conflict Minerals, please see our Valued Links from organizations and inititives of due diligence and ensuring a conflict free supply chain Click Here
1. Proactively participating in certain activities with the IPC Solder Products Value Council, EICC/GeSI, ITRI and the Conflict Free Tin Initiative.